CISCO SYSTEMS CAPITAL (INDIA) PRIVATE LIMITED

Cisco Systems Capital (India) Private Limited, a Non-Banking Finance Company registered with Reserve Bank of India ("RBI") is in the business of providing different types of loans/leases for the IT assets to its customers which are Companies and other Corporate/Legal entities.

Cisco Systems Capital (India) Private Limited ("the Company"), through its Board of Directors (the "Board"), has framed and adopted a fair practices code. The Fair Practices Code is aimed to provide to the customers effective overview of practices, which will be followed by the Company in respect of the financial facilities and services offered by the Company to its customers. This Code will facilitate the customers to take informed decisions in respect of the financial facilities and services to be availed by them and will apply to any loan that the Company may sanction and disburse. This Code is in conformity with the Reserve Bank of India’s circulars, DNBS.CC.PD.No.266 /03.10.01/2011-12 dated March 26, 2012 and the Master Circular No. DNBS (PD) CC No. 286/03.10.042/2012-13 dated July 2, 2012.

The Company's business shall be conducted in accordance with prevailing statutes and regulations, with due focus on efficiency, customer-orientation and corporate governance principles.

Objective & Commitment

The Company shall act and continually improve upon:

• Following standards for fair and transparent business practices while dealing with its customers
• Acting fairly and reasonably in all dealing with its customers and to promote a fair and cordial relationship between the customers and the Company
• Increasing transparency to enable the customers to have a better understanding of what they can reasonably expect of the services
• Making sure that the Company's offerings and services meet relevant laws and regulations
• Publishing this code on the Company's website and ensure that the published contents are not misleading
• Informing customers of the information required from them to establish customer's true identity and ask for documents to comply with prevailing statutory and regulatory "Know-Your-Customer" and Anti-Money Laundering guidelines and other legal & regulatory requirements as may be required by the RBI and other government agencies.
• Providing clear information to its customers about its various products and services, the terms and conditions on which these are offered by the Company, including the interest rates, charges, repayment terms, etc.
• Keeping the customers informed of their right to be informed about:
• o their account with the Company and the facilities extended to them by the Company;
• o changes in its interest rates and charges through individual communication or public announcement as appropriate
• Keeping the information received from its customers as confidential and not disclosing the information to others except when:
  • Required by law or by a judicial, quasi-judicial or regulatory authority;
  • obligated by government or authorities to disclose in the public interest; or
  • the Company's interest require disclosure; or
  • the customer has consented to or asked for such disclosure

Applicability

This code shall apply to the Company's employees and its duly authorized representatives / partners.

Non - Discrimination Policy

The Company will not discriminate between its customers on the basis of gender, race or religion.

Applications for Loans and their processing

• All communications to the borrowers shall be made in vernacular language or a language as understood by the borrower.
• The Company will provide to the borrowers, the necessary information such as the applicable interest rate, processing fees or charges if any, prepayment option and charges if any, so that Customer can make a meaningful comparison with the terms and conditions offered by other NBFCs and later take an informed decision.
• The above information shall be stated in the loan application forms of the Company.
• The loan application form may also indicate the documents required to be submitted with the application form.
• If any additional details / documents are required, the same shall be intimated to the borrowers immediately.
• The Company shall devise a system of acknowledging the receipt of loan applications and will inform the time needed to give a decision. Subject to receipt of all the requisite documentation and information, loan applications would be disposed of within 30 working days from the date of receipt of the application form complete in all respects. In any case the customer will be kept informed by the sales person with regards to the status of his application from time to time.

Loan Appraisal and Terms/Conditions

• The Company shall conduct a due diligence on the credit worthiness of the borrower, which will be the important parameter for taking decision on the application. The assessment would be in line with the Company’s credit policies, norms and procedures in respect thereof.
• The borrower would be informed by means of a written sanction letter in vernacular language as understood by the borrower, of the amount of loan sanctioned or otherwise. The said letter shall contain the terms and conditions including the annualized rate of interest and application thereof. All the terms and conditions will be fair and will set out customer's rights and responsibilities clearly and in plain language. Company will y use legal or technical language where necessary.
• The Company shall obtain an acceptance from the borrower on the said sanction letter with the borrowers’ signature under the caption “I/WE ACCEPT ALL THE TERMS AND CONDITIONS WHICH HAVE BEEN READ AND INDERSTOOD BY ME/US”. The Company shall maintain a record of such acceptance.

Disbursement of Loan including Changes in Terms and Conditions

• The Company shall frame appropriate internal principles and procedures for determining and ensuring that the interest rates and processing and other charges are not excessive. The Company shall, at the time of disbursal, ensure that the interest rate and processing and other charges on loans and advances are in strict adherence to above refereed internal principles and procedures.
• The disbursement will be done immediately upon compliance of all the terms and conditions of the sanction by the borrower.
• The Company shall notify in writing in the vernacular language as understood by the customers of any change in the terms and conditions including disbursement schedule, interest rates, service charges, pre-payment charges etc. before the change/s are implemented.
• The Company shall also ensure that the change in interest rates and charges shall only be effective prospectively. A suitable provision in this regard shall be incorporated in the applicable loan agreement.
• In cases of default in the loan / service agreement, the Company's decision to terminate the loan or accelerate payment or performance under such agreement shall be in accordance with the agreed terms.
• The Company shall release all securities on repayment of all monies due or on realization of the outstanding amount of loan subject to any legitimate right or lien for any other claim the Company may have against its customer. If the Company exercises any right of set off against the defaulting customer, the Company shall notify the latter with the particulars of the remaining claims and the conditions under which the Company is entitled to retain the securities until all the relevant claims are settled /paid.

General

• The Company shall refrain from interference in the affairs of the customer except for the purpose provided in the terms and conditions of the loan agreement (unless new information, not earlier disclosed by the customer, has come to the notice of the company).
• In the matter of recovery of loans, the Company shall not resort to undue harassments loke bothering the customers as odd hours, use of muscle power for recovery of loans, etc. The Company shall ensure that its staff is adequately trained to deal with the customers in an appropriate manner.
• The Company may arrange for enforcing security charged to its delinquent customers, if required, with an aim only to recover dues and will not be aimed at whimsical deprivation of the property.
• The Company will process request from the customer for transfer of borrowal account, the consent or otherwise - i.e. objection of the Company, if any, shall be conveyed to the customer within 21 days from the date of receipt of any such request. Such transfer shall be as per transparent contractual terms in consonance with law.

Customer Grievance Redressal Mechanism

• Any grievance with regard to this Code, shall be intimated to Grievance Redressal Forum comprising Amit Mehra (Credit Manager) Carol Lim (Operations Manager) and Mario Renato Navas (Director) as members. The said forum will setup a meeting within a period of six weeks from the date of receiving any grievance intimation and ensure that all disputes arising out of the decisions of lending by the Company's functionaries are suitably heard and disposed of at least at the next higher level. The Reports will be sent to the Board of Directors for its information and any action if required.
• A periodical review of the functioning of the grievances redressal mechanism would be undertaken by the Company and a consolidated report of such reviews shall be submitted to the Board of Directors of the Company at regular intervals.

Any complaint against the Company is to be addressed as follows:

By letter: Mr.Amit Mehra (Credit Manager), Cisco Systems Capital (India) Private Limited, 7th & 8th Floor, East Tower, 25 Barakhamba Road, New Delhi - 110 001

By email: capital-india@cisco.com

Policy for Determining Interest Rates, Processing and Other Charges

To ensure that there the customers are not charged excessive interest rate and charges on loans and advances by the Company, the Board of directors of the Company has adopted a Policy for Determining Interest Rates and Other Charges (“Interest Rate Policy”) and the same has been put up on the Company’s website. The changes in the interest rates are also displayed on the website on a regular basis. Further the Board of the Company also undertakes periodical review of the Interest rate Policy.

Wide Dissemination and Periodic Review

The Company shall put the above Fair Practices Code on its website, for the information of various stakeholders. The Company shall also review and refine this Code, as may be required periodically - based on its own experience and fresh guidelines, if any, to be issued by the RBI in this regard.